- 12 -
corroborating evidence. See Tokarski v. Commissioner, 87 T.C. at
77. Consequently, we sustain respondent’s determination
disallowing petitioner any dependency exemptions for 1982 and
1986.
D. Conclusion
We sustain respondent’s determinations of income tax
deficiencies for the taxable years at issue.
II. Additions to Tax for Fraud
Section 6653(b)14 authorizes the imposition of an addition
to tax for underpayments of tax due to fraud. Before amendments
by the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 1085
(the 1986 amendments), the addition to tax for fraud consisted of
50 percent of the underpayment amount, plus 50 percent of the
interest due on the portion of the underpayment attributable to
fraud. Sec. 6653(b)(1) and (2). After the 1986 amendments,
section 6653(b)(1) and (2) became section 6653(b)(1)(A) and (B),
respectively, and imposed an addition to tax for fraud of 75
percent of the portion of the underpayment attributable to fraud,
plus 50 percent of the interest due on that portion of the
underpayment. Section 6653(b)(1) and (2) governs petitioner’s
income tax liabilities for 1982 through 1985; section
14Sec. 6653(b) was amended by the Technical and
Miscellaneous Revenue Act of 1988, Pub. L. 100-647, sec.
1015(b)(2)(B), 102 Stat. 3569, and the Omnibus Budget
Reconciliation Act of 1989, Pub. L. 101-239, sec. 7721(c)(1), 103
Stat. 2399. Sec. 6663(a) contains the current version of the
fraud penalty.
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